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Ack Receipt of 860530 & 0707 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/86-16
	ML20207E793
Person / Time
Site:	River Bend
Issue date:	07/16/1986
From:	Gagliardo J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill; GULF STATES UTILITIES CO.
Shared Package
ML20207E797	List: ML20207E793; RBG-23964, Suppls Response to NRC Re Violations Noted in Insp Rept 50-458/86-16.Corrective Action:General Maint Procedure GMP-0092 Being Developed as Alternative to Torque Wrench Program;
References
	NUDOCS 8607220425
	Download: ML20207E793 (2)
	v • d • e

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                                     ,,     JUL 1 6M
   In' Reply Refer To:
   Docket: 50-458/86-16
   Gulf States Utilities
   ATTN: William J. Cahill, Jr.,
            Senior Vice President
            River Bend Nuclear Group
   P. O. Box 2951
   Beaumont, Texas 77704
   Gentlemen:
          Thank you for your letters, dated May 30, 1986, and July 7, 1986, in
   response to our letters, dated May 1,1986, and June 13, 1986. We have no
   further questions at this time and will review your corrective action during a
   future inspection.
                                                  Sincerely,
                                                    Original signed By
                                                     1 E. Gagliardo
                                                  J. E. Gagliardo, Chief
                                                  Reactor Projects Branch
   cc:
   Gulf States Utilities
   ATTN:     J. E. Booker, Manager-
                Engineering, Nuclear
                                                                         ^
                                                                       >
                Fuels & Licensing
   P. O. Box 2951                                                          ,
   Beaumont, Texas 77704
   Louisiana Statt University,
      Government Documents Department                            -
                                                                             '
   Louisiana Radiati           ontrol Program Director
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              GULF STATES                       UTILITIES COMPANY
                                                                                                                 }
                       RIVER BEND STATION     POST OFFICE BOX 220    ST FRANCISVILLE. LOUISIANA 70775
                                          ARE A CODE 504    635 6094     346 8651
                                                                                         May 30, 1986
                                                                                         RBG- 23800
                                                  .                                      File Nos. G9.5, G15.4.1
          Mr. Robert D. Martin, Regional Administrator
          U.S. Nuclear Regulatory Commission
          Region IV                                                                               F          - - -
                                                                                                                        -' ---- ,
          611 Ryan Plaza Drive, Suite 1000                                                        l[[ ha ij [N b,.    2
          Arlington, TX 76011                                                                        'I
          Dear Mr. Martin:                                                                          'i   M - 419f6
                                     River Bend Station - Unit 1
                                           Refer to: Region IV                                  ~
                                                                                                                   _
                                 Docket No. 50-458/ Report 86-16
          This letter responds to the Notice of Violation contained in NRC
          I&E Inspection Report No.                       50-458/86-16.                   The inspection was
          performed by Mr. Michael E. Skow during the period March 31
          through April 4, 1986 of activities authorized by NRC Operating
          License NPF-47 for River Bend Station - Unit 1.                                                                         .
          Gulf States Utilities Company's                               (GSU)          response to Notice of
          Violation 86-16-01,              " Failure to Have Adequate                                   Procedures",
          86-16-02,  " Failure to Follow Procedures", and 86-16-03, " Failure
          to Follow Procedures", are provided in the enclosed attachment.
          This completes GSU's response to the Notice of Violation.
                                                                              Sincerely,
                                                                                          o
                                                                             W. J. Cahill, Jr.
                                                                              Senior Vice President

( River Bend Nuclear Group

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                                                         ATTACHMENT 3
                               RESPONSE TO NOTICE OF VIOLATION 50-458/8616-02

                                                           LEVEL V
                                                                                          e

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                 C.   FAILURE TO FOLLOW PROCEDURES

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                      REASON FOR THE VIOLATION
                      Station Support Procedure              (SSP)-1-004, Revision          0      (Station
                      Document Control System)              states that the IS-217 Report is the

,

                      primary document for identifying outstanding changes against. Stone

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                      and Webster design documents. However, a modified IS-217 Report
                      exists that identifies changes in the form of Pipe Support
                      Revision Notices     (PSRNs)          to Category II and III large bore pipe
                      support design drawings (i.e. , BZ/PSDD drawings).                  The modified

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                      IS-237 is not addressed in ESP-1-004.                    Station Document Control

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                       (SDC) was not aware of the existence                 of PSRNs or the modified
                      IS-217.   Both documents had been previously distributed by Stone &

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                      Webster (S&W) Document System Group                     prior to this           group's
                      consolidation with GSU Station Document Control in late 1985.
                      PSRNs were no longer being originated by S&W at                     the time of
                      consolidation    but some of those previously issued are not
                      incorporated into their respective drawings, thus, they are still
                      outstanding changes.
                      CORRECTIVE STEPS WHICH HAVE BEEN-TAKEN AND THE RESULTS ACHIEVED-

l The modified IS-217 is addressed in the Stone and Webster l Engineering Corporation Plant Services Procedure (PSP)-3.1-0,

" Applicability of Construction Phase Interim Design Change

                      Mechanism to Operation", dated August 28, 1985.                       An approved
                      change to SSP-1-004 has been implemented which addresses the
                      modified IS-217 Report and references PSP-3.1-0.                  SSP-1-004 also
                      discusses the need for using both the IS-217 and the modified
                      IS-217 to ensure a BZ/PSDD is current.

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                      CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

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                      The modified IS-217 will be distributed on a as-needed basis to
                      document satellite stations.                 Since the IS-217 Report and the
                      modified IS-217 Report are the only documents available for
                      identifying outstanding changes against Stone and Webster design
                      documents, this is determined to be an isolated case.
                      DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

l Full compliance has been achieved. l l l

  ___                  ___                   ___                    _ - _ -     ___                __ _ _

                                         .                  _.           - ._ -                  -        _         -          -           .        --                      .     -.
      .               .
  ,                                                                                         ATTACHMENT 2
                                              RESPONSE TO NOTICE OF VIOLATION 50-458/8616-03

. LEVEL V

               B.            FAILURE TO FOLLOW PROCEDURES
                             REASON FOR THE VIOLATION
                                                                                                                                                                                       ,
                             Procedure ADM-0005, Revision 4 (Station Document Control) requires
                             that documents transmitted to satellite stations- offsite be                                                                                            -"
                             incorporated into manuals, etc. and the transmittal signed and
                             returned within 10 working days of the date on the transmittal.
                             Contrary to this requirement, 17 document transmittals older than
                              10 working days had not been incorporated into manuals located in
'
                             the Emergency Operating Facility                                                          (EOF).  Emergency                          Response

i Personnel were not updating EOF documents as required by ADM-0005. , Also, Station Document . Control (SDC) had not sent Delinquent s Notices to the satellite station as also required by ADM-0005.

                            Root cause of the problem appears to be a change in F.OF personnel
                            resulting in responsibility for updating documents not being
,                           carried over and. leniency on the part of SDC because of the new

l personnel in EOF.

                            CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED

I All documents were incorporated into their respective manuals on

                            the day that the discrepancy was discovered by the NRC Inspector.
                           The transmittals were then signed and returned to SDC. The EOF
                           Satellite Station is now in compliance with ADM-0005 requirements.

                           CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOILATIONS
                           The new EOF personnel were given training by the SDC Supervisor to
                           ensure               they                         understood             their             satellite station custodial

j responsibilities. Documentation is available to support the

                           training given.                                      Station Document Control personnel have been

i

                           verbally instructed to comply with ADM-0005 requirements for

issuing Delinquent Notices. A memorandum has been issued !

) restating the verbal instructions given to SDC personnel. . [ DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED j Full compliance has been achieved.

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, required to be performed in accordance with the
ADM-0029. To ensure compliance with ADM-0029, Memorandum controls of
No.
APM-M-86-59 was issued on April 2, 1986 rescinding th'e new program
described in Memorandum No. PMG-M-86-62, dated March 25, 1986.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
The responsible
requirements Plant Staff Maintenance personnel are aware of the
of ADM-0003.
is presently being developedGeneral Maintenance Procedure, GMP-0092
as an alternative to the
torque
wrench program described in ADM-0029. The procedure will meet the
intent of the program described in Memorandum No. PMG-M-86-62 and
establish
torque wrenches.
approved instructions for the calibration and control of
The approval of GMP-0092 is presently pending
the receipt
device.
of a newly purchased torque
Torque wrenches will remain
wrench calibration check
under the controls of
approved procedure ADM-0029 until GMP-0092 is approved and issued.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Full compliance
March
with the requirements of ADM-0029 was achievei on
27, 1986 after the relocation of the torque wrench
calibration check device.
,

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", , , ATTACHMENT 1

                      RESPONSE TO NOTICE OF VIOLATION 50-458/8616-01
                                                 LEVEL IV
  Reference
  Notice         of Violation - J. E. Gagliardo to W.          J. Cahill, Jr. dated May
  1,   1986.
  A.    FAILURE TO HAVE ADEQUATE PROCEDURES
        REASON FOR THE VIOLATION
        On March 25, 1986, in Memorandum No. PMG-M-86-62, the Plant Staff
        Maintenance Department removed torque wrenches from the controls
        of Administrative Procedure ADM-0029, " Control of Measuring and
        Test        Equipment       (M&TE)",       and provided new instructions for
        controlling torque wrenches. These program changes were made to
        provide controls for more reliable torque wrench calibrations by
        requiring the torque wrenches to have a calibration check before
        and after each use on plant equipment. The new program also
        expedited the process of issuing torque wrenches to Maintenance
        personnel.          The M&TE device used to check the torque wrench
        calibrations remained under the control of ADM-0029.                     The new
        instructions also continued the use of M&TE Tracking Cards, as
        required by ADM-0029. Although the memorandum, issued on March
        25,       1986,   did cctablich controls for using torque wrenches at
        River Bend Station, the failure to implement an approved procedure
        in accordance with the requirements of ADM-0003 resulted in an
        apparent violation of Technical Specification Section 6.8.1.
        CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
       The new program, as described in Memorandum No. PMG-M-86-62, was
       discontinued on March 27, 1986 when the torque wrench calibration
        check device was relocated from the Maintenance Shop to the Site
        Standards Laboratory.                 This change resulted from the device's
       calibration having been suspected as out of tolerance.                       When
        returned to the Standards Laboratory, the device's calibration was
       confirmed to be out of tolerance by a 1.4 percent error for
       readings above 225 ft-lbs when used in the counter clockwise
       direction. A review of the M&TE Tracking Cards for the torque
       wrenches used during the 3 days of the new program, revealed that
       the torque wrenches in question were not used in the counter
       clockwise direction or in the ranges found out of tolerance.
       Therefore, all torque wrench applications during this period were
       acceptable.
       As a result of the calibration check device being removed from
       service on March 27, 1986, subsequent torque wrenches issued were
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. UNITED STATES OF AMERTCA
EUCLEAR EECUIATORT CGESSION
.
STATE OF ISUISIAEA 5
FARISE OF WEST FILICIAEA $ .
In the Matter of I Docket Bos. 50-458
CULF STATES UTILITIES CGEFANY l
(River Bend Station,
Unit 1)
AFFIB&VIT
W. J. Cahill, Jr., being duly sworn, states that he is a Senior
Vice President of Gulf States Utilities Company; that he is authorized
on the part of said Company to sign and file with the Nuclear Rggulatory
Coorsis sion the documents attached heretos and that all such documents
are true and carrect to the best of his knowledge, information and belief.
/ ,
W. Cahill, Jr. /[

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                                                                                                                      ..
                                   Subscribed and sworn to before me, a Notary Public in and for the

! State and Parish above named, this M day of M a &7 ,19M.

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                                                                                                  $AK d       *
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                                                                                                                              N
                                                                                               ~an W. Middlebrooks L

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                                                                                              totary Public in and for

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                                                                                            West Feliciana Parish,
                                                                                            Louisiana
                              My Conunission is for Life.

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ML20207E793

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